The R2 Standard is the leading certification for electronics repair and reuse. As the housing body for R2, SERI maintains the R2 Standard, related documentation, guidance, and facilitates its ongoing development.

SERI works with partners throughout the lifecycle of electronic products to ensure that they are managed responsibly. SERI's programs focus on education, outreach, safety, and international development.

SERI offers a variety of educational and training opportunities for recyclers, as well as opportunities for auditors and consultants. These trainings focus on implementing the R2 Standard, realizing a return on the investment in certification, discussing relevant issues or challenges related to recycling practices, and other topics.

Documenting the flow of materials: What your auditor will expect to see

Dec. 27, 2017

Tracking the flow of equipment, components, and materials that pass through an R2 Recycler’s facility is one of the fundamental pillars of the R2 Standard. Auditors will be looking for an effective sampling of records, such as Bills of Lading (BOLs) or other equivalent, commercially accepted documentation that demonstrates conformance to the R2 Standard. Among the records used to corroborate your documented flow of Focus Materials (FMs) down the recycling chain could be BOL’s signed by the receiving facility, settlement reports, invoices, and receipts of payment.

Provision 5(e)(6) requires each recycler to verify that their Tier 1 downstream vendors “Conform to Provision 7, documenting the flow of all FMs down the Recycling chain.”

Provision 7 (a) requires BOLs or other commercially acceptable documentation to be maintained for all transfers of equipment, components and materials. An auditor will expect to see evidence from the R2 recycler that their Tier 1 DSVs are conforming to Provision 7. When performing due diligence of the Tier 1 DSV, the R2 recycler should demonstrate conformance by sampling BOLs or other commercially accepted documentation from each Tier 1 DSV to each Tier 2 DSV. This applies to the qualification of both an R2 and Non-R2 certified Tier 1 DSVs.

Q: Do I need to collect BOLs between every downstream vendor in my recycling chain all the way through to end-of-life?

While it is not necessary to collect BOLs for every shipment for every downstream vendor in the recycling chain, you may need to collect a sample of business records to confirm the flow of FMs (Provision 5.e.6). The R2 Recycler is responsible for the validity of the “flow of all FMs down the recycling chain.” The auditor may request proof that sufficiently demonstrates the transfer of FMs, and equipment and components containing FMs, between the DSVs listed in your recycling chain.

Q: How often do I need to sample and verify BOL’s?

Provision 5(f) requires, “An R2:2013 electronics recycler shall confirm at least annually and document, through audits or other similarly effective means, that each downstream facility to which Section (e) applies continues to conform to the requirements of Section (e) for as long as it receives FMs directly or indirectly from the R2:2013 electronics recycler.”

Q: How do I effectively sample BOLs from my downstream vendors?

In a few situations, we have seen shipment documentation between DSVs that is not consistent. We have even seen documentation that has been visibly altered. It is important to sample documentation with an eye for such situations:

Ensure BOLs provided by the Tier 1 DSV are for the types of equipment, components, and materials that you send to the Tier 1 DSV. If the Tier 1 sends the equipment, components, or materials out for further processing, you should collect sample BOLs from your Tier 1 to each Tier 2 DSV that is receiving the material (or outputs from the material).

Ensure the name and address of the Tier 2 noted on the BOL matches the name and address of noted in the Tier 1’s documented “flow of all FMs down the Recycling Chain.”

Ensure the name, address, and scope stated on the receiving vendor’s R2 Certificate, matches the company information and the product(s) listed on the BOL.

Match invoices or payments to BOLs to verify receipt of the Focus Materials by the Tier 2 vendor.

Choose a larger sample for Tier 1 downstream vendors that are not R2 Certified.

Choose a larger sample for international shipments.

Q: Do I need to show proof that a downstream vendor in another country legally imported/exported the equipment or components if it shipped from a downstream vendor’s facility in my recycling chain?

Yes – Provision 3.a.2, Import/Export Compliance, applies to all untested or non-functioning equipment or components containing FMs that have passed through the R2 facility or its control. In the footnote, it clarifies “This includes shipments made by downstream vendors.” This includes shipments imported or exported by R2 Certified recyclers, as well as Non-R2 Certified downstream vendors.

*Tier 1 refers to those DSVs that receive direct shipments from an R2 recycler. If the Tier 1 DSV sends the material (including equipment and components) out for further processing, the second processor would be considered the R2 recycler’s Tier 2 DSV. If the Tier 2 DSV sends material out again, the next processor would be the R2 recycler’s Tier 3 DSV, and so on.

The R2 Standard is the leading certification for electronics repair and reuse. As the housing body for R2, SERI maintains the R2 Standard, related documentation, guidance, and facilitates its ongoing development.

SERI works with partners throughout the lifecycle of electronic products to ensure that they are managed responsibly. SERI's programs focus on education, outreach, safety, and international development.

SERI offers a variety of educational and training opportunities for recyclers, as well as opportunities for auditors and consultants. These trainings focus on implementing the R2 Standard, realizing a return on the investment in certification, discussing relevant issues or challenges related to recycling practices, and other topics.